Burr Eckstut

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State Securities Regulators Step Up Scrutiny of Cryptoassets and ICOs

On October 10, the North American Securities Administrators Association (“NASAA”)—an association of state, provincial, and territorial securities regulators in the United States, Mexico, and Canada—released its annual Enforcement Report (the “Report”). The Report demonstrates that, while stepped-up enforcement activity has been observed at the federal level with respect to cryptoasset markets, state regulators are increasingly … Continue Reading

Regulators Encourage Lower-risk Banks to Join Forces for Bank Secrecy Act and AML Compliance

On October 3, the Board of Governors of the Federal Reserve System (“Federal Reserve”), the Federal Deposit Insurance Corporation (“FDIC”), the National Credit Union Administration (“NCUA”), the Office of the Comptroller of the Currency (“OCC”), and the U.S. Department of Treasury’s Financial Crimes Enforcement Network (“FinCEN”) released an Interagency Statement on Sharing Bank Secrecy Act … Continue Reading

German Federal Financial Supervisory Authority Publishes Guidance on the Regulatory Framework for Cloud Services

The German Federal Financial Supervisory Authority (“BaFin”) recently published an article that provides guidance on the regulatory framework for cloud computing.  This is a follow-up to the circular letter Minimum Requirements for Risk Management (“MaRisk”), which was published in German in October 2017 and the circular letter Supervisory Requirements for IT in Financial Institutions (“BAIT”), … Continue Reading

California Considers a New Blockchain-Related Bill

California has taken a conservative step on the path to greater regulation of blockchain technology or legal recognition of blockchain-secured data.  On May 18, an amended bill was referred to the State Assembly Appropriations Committee for review that would provide for the establishment of a blockchain working group to evaluate “the potential uses, risks, and … Continue Reading

Australia and Malta Adopt Different Approaches to Cryptocurrency and Blockchain Regulation

The Australian Transaction Reports and Analysis Center (“AUSTRAC”) recently implemented a new regulation for digital currency exchange providers operating in Australia called the Anti-Money Laundering and Counter-Terrorism Financing (Digital Currency Exchange Register) Policy Principles 2018.  AUSTRAC is Australia’s financial intelligence agency and is responsible for the enforcement of Australia’s Anti-Money Laundering and Counter-Terrorism Financing Act … Continue Reading

Treasury Issues Regulatory Reform Recommendations for the Orderly Liquidation Authority

On Wednesday, February 21, the Treasury Department issued a report regarding the Orderly Liquidation Authority (“OLA”) established by Title II of the Dodd-Frank Act under which the FDIC may be appointed as receiver of a severely distressed and systemically important financial company. This report was prepared in response to the President’s April 21, 2017 memorandum … Continue Reading
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